The National Association of Broadcasters (NAB), the Consumer Electronics Association (CEA) and other organizations and companies with an interest in the distribution of video programming filed comments in the FCC's Notice of Inquiry regarding the Annual Assessment of the Status of Competition in the Market for the Delivery of Video Programming. NAB and CEA used the filing to restate their data on TV viewing habits, with CEA downplaying the importance of the off-air TV signal and NAB emphasizing how many people rely on off-air TV for at least some of their TV viewing. However, both CEA and NAB recognized that is important not to disenfranchise those viewers who depend on over-the-air reception.

CEA reported that its research indicates three-quarters of antenna-only households are willing to take some voluntary action to continue receiving TV after analog broadcasting ends. I was surprised to see that only 9 percent of the households in the survey said they would start subscribing to cable or satellite once analog TV is shut off. Of the other households in the survey, 42 percent would buy a $60 set-top converter and 22 percent indicated they would by a new TV capable of receiving DTV signals. Twenty-two percent said they would do nothing, since they don't use the TV to receive off-air broadcasts. CEA projections indicated that by 2009, Americans would buy 152.3 million DTV tuners in integrated DTV sets or in set-top boxes. Currently, CEA stated, consumers can choose from over 200 integrated DTV sets that include off-air DTV tuners. Of all DTV products sold, CEA said HDTV displays and receivers represent 85 percent of the products.

CEA criticized the cable industry for lack of support for CableCARD products in digital cable ready (DCR) TV sets. CEA said that while there are more than 1,000,000 DCR sets on the market, only 55,000 CableCARDs have been deployed. In my opinion, the success of DCR TV sets and CableCARD products is important not only to electronics manufacturers, but to broadcasters and consumers as well. DCR TV sets have to include an off-air tuner, which benefits broadcasters. If a cable system provides CableCARDs at a reasonable price, consumers can view digital cable channels on any DCR TV set or CableCARD capable device hooked up to cable in their house, without renting or purchasing a proprietary set-top box for each TV set. CEA said, "In our experience, the only way to assure competitive supply of digital cable set-top boxes and digital cable ready TV sets is to ensure that the devices supplied by cable operators rely on the same CableCARDs for security that must be used by equipment supplied through competitive retail outlets. This not only will assure a steady supply of CableCARDs, but also will provide incentive for cable operators to keep the CableCARD system reliable, up-to-date, and competitive with their own embedded security system. The Commission must ensure the integrity of its regulation concerning these devices and maintain July 1, 2007, as the date by which digital devices supplied by cable operators must meet these requirements."

In its comments, CEA said broadcasters "must more aggressively promote digital broadcast channels, both during analog broadcasts and in TV program listings." It also urged the FCC to take a close look at DTV build-out waiver requests from broadcasters requesting operation at less than full power.

NAB repeated its previous findings that approximately 73 million TV sets depend on off-air TV signals, more than twice the number CEA found in its research, but less than the 80 million sets identified by the Consumers Union and the Consumer Federation of America.

NAB stated that a total 1,525 stations in 211 TV markets are broadcasting digital signals and the major broadcast networks provide their most popular programming in high definition. It also noted that hundreds of local stations are multicasting on their digital channels and many more are considering multicasting. NAB said multicast programs include news, weather, sports, religious material, foreign language programming and innovative entertainment programming.

To illustrate how broadcasters are working to help consumers convert to DTV, NAB described its program to spur development of a low cost, high quality digital to analog converter box for terrestrial DTV reception. NAB also outlined its efforts to educate consumers about the DTV transition, pointing to a four-spot "DTV Lessons" services it offered its TV station members and creation of the CheckHD.com Web site.

I'm encouraged to see that while CEA and NAB have different opinions on number of off-air TV sets, both organizations are committed to helping consumers make the transition to DTV. While the CEA filing continued to emphasize the important of HDTV, these comments did not criticize the use of multicasting.